Arrest safeguards and transit remand requirements invalidated detention following inter-State transfer without communicated grounds or magistrate auth...
Arrest safeguards require disclosed grounds, relative intimation and transit remand, while duplicate prosecution under the CGST framework is unsustain...
Document Identification Number defects can invalidate GST assessments, with delayed challenges entertained conditionally where patent irregularities e...
Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
ITAT upheld the appellate order, finding the taxpayer acted as agent of its principal (AE) and that 50% of documentation and telex charges were proper reimbursements credited in the books on a principal-and-agent basis rather than assessable international transactions for ALP adjustment. The Tribunal recorded that amounts received were held on behalf of the principal, corresponding expenses were not borne by the taxpayer, and the charge allocation corroborated by Form 3CEB supported agency treatment. Relying on authoritative SC precedent addressing like facts and absent contrary judicial authority or ALP adjustments in adjacent years, ITAT dismissed Revenue's grounds and affirmed there was no infirmity in the impugned appellate order.
ITAT upheld the appellate order, finding the taxpayer acted as agent of its principal (AE) and that 50% of documentation and telex charges were proper reimbursements credited in the books on a principal-and-agent basis rather than assessable international transactions for ALP adjustment. The Tribunal recorded that amounts received were held on behalf of the principal, corresponding expenses were not borne by the taxpayer, and the charge allocation corroborated by Form 3CEB supported agency treatment. Relying on authoritative SC precedent addressing like facts and absent contrary judicial authority or ALP adjustments in adjacent years, ITAT dismissed Revenue's grounds and affirmed there was no infirmity in the impugned appellate order.
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